Wayne and Lois Hampton - Page 5




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          failed to attend various scheduled meetings with respondent’s               
          representatives and failed timely to produce records.                       
               Respondent’s audit, respondent’s Appeals Office                        
          consideration, and the ultimate settlement of petitioners’ case             
          in this Court all appear to have been delayed by the haphazard              
          fashion in which petitioners produced their records.                        
               On the limited record before us in this case, we conclude              
          that petitioners’ delay in producing records protracted the                 
          administrative and court proceedings within the meaning of                  
          section 7430(b)(3).  Petitioners are not entitled to an award of            
          any litigation costs.  See Polyco, Inc. v. Commissioner, 91 T.C.            
          963, 968 (1988).                                                            
               To reflect the foregoing,                                              
                                                   An appropriate order and           
                                             decision will be entered.                






















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